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Planned Maintenance, Startup, and Shutdown – Other Industries

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Planned Maintenance, Startup, and Shutdown – Other Industries. Mike Coldiron , P.E. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2012. What Are Planned MSS Emissions?. - PowerPoint PPT Presentation
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Planned Maintenance, Startup, and Shutdown – Other Industries Mike Coldiron , P.E. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2012
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Page 1: Planned Maintenance, Startup, and Shutdown –  Other Industries

Planned Maintenance, Startup, and Shutdown –

Other Industries

Mike Coldiron , P.E.Air Permits Division

Texas Commission on Environmental QualityAdvanced Air Permitting Seminar 2012

Page 2: Planned Maintenance, Startup, and Shutdown –  Other Industries

What Are Planned MSS Emissions?

• Planned MSS emissions include air emissions resulting from the maintenance, startup, or shutdown of equipment or facilities at a site

Page 3: Planned Maintenance, Startup, and Shutdown –  Other Industries

What Are Planned MSS Emissions?

• Part of normal or routine facility operations other than production operations

• Predictable to timing

• Do not have to be scheduled for a specific date or time

Page 4: Planned Maintenance, Startup, and Shutdown –  Other Industries

What Are Planned MSS Emissions?

• Do not include unplanned MSS, upsets, or emission events– TCEQ does not permit unplanned MSS,

upsets, or emission events– Emission events are covered under 30

TAC §101.201

Page 5: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Permitting – Other Industries

• Diversity very different from previous industry groups

• Different industry demographics - small businesses and minor sources (sites)

Page 6: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Permitting Goals – Other Industries

• Reduce the amount of effort for staff and regulated community

• Reduce processing times

• Efficiently review MSS from the large number of permitted sources anticipated for the 2013 submittal

Page 7: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Permitting – Previously Permitted Industries

Number of Applications Received by DateRefineries 26 January 5, 2007

Chemical plants 400 January 5, 2008

Carbon black 6 January 5, 2010

Power plants 103 January 5, 2011

Page 8: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Permitting – Coatings Industry

Foam Manufacturing 35

Printing 55

Fiber Reinforced Plastics/Cultured Marble 91

Paint, Coatings, Ink, and Adhesive Mfg. 43

Degreasing 18

Semiconductors and Electronics 32

Enclosed Painting 297

Non-enclosed Painting 43

Abrasive Blasting 23

Miscellaneous 56

Page 9: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Permitting – Mech/Ag/Construction Industry

Cotton Gins 267Grain Elevators 693Concrete Batch Plants 1015Hot Mix Asphalt Plants 284Rock Crushers 488Feed Mills 81

Total number of Mechanical Section applications is expected to exceed 3000

Page 10: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Permitting – Chemical Process Industry

Bulk and Marine Terminals 199Cleaning Facilities (i.e., railcar cleaning)

86

Refuse and Offsite Treatment 38Chemicals and Allied Services 37

Page 11: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Permitting – Planned MSS Groupings

• Evaluated possible MSS activities for each industry type

• Created groupings of similar industry types with similar MSS activities

• Discussed options for authorizing those activities

Page 12: Planned Maintenance, Startup, and Shutdown –  Other Industries

Activity Categories for MSS

• Process MSS

• General facility MSS– Included in other industry submissions– Impacts issues are difficult to deal with

Page 13: Planned Maintenance, Startup, and Shutdown –  Other Industries

Approach for Process MSS Activities

• Identified specific facility types

• Identified for each facility type– What is MSS– What is not MSS (normal process)

• MSS activities may be common to different facilities

• Authorization options

Page 14: Planned Maintenance, Startup, and Shutdown –  Other Industries

Process MSS Authorization Options

• Already authorized in current permit explicitly or implicitly

• PBR – 30 TAC Chapter 106– No registration in most cases– Simple (or no) recordkeeping– No BACT review or public notice– Limited (or no) impacts review

Page 15: Planned Maintenance, Startup, and Shutdown –  Other Industries

Process MSS Authorization Options

• De minimis – 30 TAC §116.119– No registration– Simple (or no) recordkeeping– No BACT review or public notice– Limited impacts review

Page 16: Planned Maintenance, Startup, and Shutdown –  Other Industries

Examples of Process MSS Using PBR §106.263

• Temporary control devices for degassing

• Thermal control device startup and shutdown

• Process piping replacement or repair

Page 17: Planned Maintenance, Startup, and Shutdown –  Other Industries

Approach for General Facility MSS

• Identify common activities• Approach to authorization

– De minimis under 30 TAC §116.119– PBR

Page 18: Planned Maintenance, Startup, and Shutdown –  Other Industries

General Facility MSS Authorization Options

• De minimis – 30 TAC §116.119– No registration– Simple (or no) recordkeeping– No BACT review or public notice– Limited impacts review

Page 19: Planned Maintenance, Startup, and Shutdown –  Other Industries

General Facility MSS Authorization Options

• PBR – 30 TAC Chapter 106– No registration in most cases– Simple (or no) recordkeeping– No BACT review or public notice– Limited (or no) impacts review

Page 20: Planned Maintenance, Startup, and Shutdown –  Other Industries

Examples of General Facility MSSDe Minimis - §116.119

• Glove box blasting cabinets

• Aerosol cans (< 64 ounces/day)

• Vehicle/equipment washing

Page 21: Planned Maintenance, Startup, and Shutdown –  Other Industries

Examples of General Facility MSSDe Minimis - §116.119

• Instrument calibration/leak checking

• Non-aerosol lubricants

• Aqueous detergents

Page 22: Planned Maintenance, Startup, and Shutdown –  Other Industries

Examples of General Facility MSS Using PBRs

• Facility painting/blasting: §106.263

• Parts cleaners: §106.454

• Welding: §106.227

• Hand-held equipment: §106.265

Page 23: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Authorization Requirements - Amendments

• Identify planned MSS activities • Quantify emissions

• BACT required– May include restrictions on activities– May be work practices

Page 24: Planned Maintenance, Startup, and Shutdown –  Other Industries

MSS Authorization Requirements - Amendments

• Impacts analysis required – Use MERA– Air dispersion modeling may be required

• Public notice may be required – New air contaminants – Increased emissions > PN Triggers

Page 25: Planned Maintenance, Startup, and Shutdown –  Other Industries

Implementation Tools – Coatings Sources

• Form PI-MSS for surface coating sources

• Example application based on Form PI-MSS

• Updated MSS BACT Tables

• Frequently Asked Questions

Page 26: Planned Maintenance, Startup, and Shutdown –  Other Industries

Implementation Tools – Mech/Ag/Construction

Industry• Survey to gather information

• Outreach to industry

• Early MSS review

Page 27: Planned Maintenance, Startup, and Shutdown –  Other Industries

Implementation Tools – Chemical Sources

• Chemical Section Toolbox on Air Permits page of TCEQ Web site will include the following:– Guidance documents– Instructions– Calculation spreadsheets– BACT tables– FAQs

Page 28: Planned Maintenance, Startup, and Shutdown –  Other Industries

Summary• Applications for “other sources” are due

by 01/05/13

• Timely applications will preserve the affirmative defense

• BACT and an impacts analysis will be required for permit amendments

Page 29: Planned Maintenance, Startup, and Shutdown –  Other Industries

Summary• Use PBR or de minimis for general

facility MSS activities

• Use the implementation tools developed by APD

• Work with APD during application development

Page 30: Planned Maintenance, Startup, and Shutdown –  Other Industries

Phone Numbers

APIRT: (512) 239-3075 APD: (512) 239-1240 or

1250

Page 31: Planned Maintenance, Startup, and Shutdown –  Other Industries

Contact Information

Contact information for the Coatings MSS Team is located on the announcements page of the TCEQ Web site.

[email protected]

Page 32: Planned Maintenance, Startup, and Shutdown –  Other Industries

Contact Information

Mike Coldiron, P.E.

(512) 239-5027

[email protected]


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